Life Ins. Fund Elite, LLC v. Hamburg Commercial Bank AG

2024 NY Slip Op 30014
CourtNew York Supreme Court, New York County
DecidedJanuary 3, 2024
StatusUnpublished

This text of 2024 NY Slip Op 30014 (Life Ins. Fund Elite, LLC v. Hamburg Commercial Bank AG) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Life Ins. Fund Elite, LLC v. Hamburg Commercial Bank AG, 2024 NY Slip Op 30014 (N.Y. Super. Ct. 2024).

Opinion

Life Ins. Fund Elite, LLC v Hamburg Commercial Bank AG 2024 NY Slip Op 30014(U) January 3, 2024 Supreme Court, New York County Docket Number: Index No. 153100/2023 Judge: Melissa A. Crane Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 153100/2023 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 01/03/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. MELISSA A. CRANE PART 60M Justice ----------------------------------------------------------------- ----------------X INDEX NO. 153100/2023 LIFE INSURANCE FUND ELITE, LLC., MOTION DATE 09/12/2023 Plaintiff, MOTION SEQ. NO. 002 - V -

HAMBURG COMMERCIAL BANK AG, CERBERUS EUROPEAN CAPITAL ADVISORS, LLP., PROMONTORIA DECISION + ORDER ON HOLDING 260 BV, MOTION

Defendant. ------------------------------------------------------------------- --------------X

The following e-filed documents, listed by NYSCEF document number (Motion 002) 19, 20, 21, 22, 23, 34,40,41,42,43,44,46,47 were read on this motion to/for DISMISS

Defendants Hamburg Commercial Bank AG ("HCOB"), Cerberus European Capital

Advisors, LLP ("Cerberus European"), and Promontoria Holding 260 BV ("Promontoria") have

moved to dismiss Plaintiff Life Insurance Fund Elite, LLC' s ("LIFE") complaint pursuant to CPLR

321 l(a)(l), (5), (7), and (8). At oral argument on September 12, 2023, the court dismissed the third

cause of action (breach of fiduciary duty against HCOB), sixth cause of action (civil conspiracy

against Cerberus European), and seventh cause of action (demand for an accounting against

HCOB). The court denied dismissal of the first cause of action (2013 breach of duty of commercial

reasonableness against HCOB). The court otheiwise reserved on the motion to dismiss. For the

following reasons, the court denies the remainder of Defendants' motion to dismiss in its entirety.

FACTUAL AND PROCEDURAL BACKGROUND

This case arises from Defendants' alleged failure to dispose of collateral in a reasonable

manner that Defendants obtained from Plaintiff after Plaintiff defaulted on a loan. LIFE is a

"private equity fund that invested in life insurance policies held by a non-discretionary trust"

153100/2023 LIFE INSURANCE FUND ELITE, LLC. vs. HAMBURG COMMERCIAL BANK AG ET Page 1 of 18 AL Motion No. 002

[* 1] 1 of 18 INDEX NO. 153100/2023 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 01/03/2024

(Complaint, NYSCEF Doc. No. 1, i1 2). As part of this business, HSH Nordbank ("HSH"),

HCOB's predecessor, agreed to loan LIFE up to $150,000,000 in 2007 pursuant to a Loan Security

Agreement between HSH, LIFE, and LIFE' s subsidiary ISM Insurance Agency, LLC ("ISM

Agency") (id., ,i 20; Loan Security Agreement ["LSA"], NYSCEF Doc. No. 2). A portfolio oflife

insurance policies secured the loan (Complaint, ,i,i 21-25). Under the LSA, HSH could "at any

time sell to one or more Qualified Purchasing Lenders 1 (an 'Assignee'), all or any part of its rights

and obligations under [the] Agreement" (LSA, § 11.14[a]). Additionally, while HSH could "sell

or offer to sell participating interests in the Note ... without the consent of, or notice to, [LIFE] .

. . [HSH] [would] retain the sole right and responsibility to exercise the rights of [HSH], and

enforce the obligations of the Loan Parties" (id., § 11.14[b ]). In the event of a sale of participating

interests in the Note, "[n]o Participant [would] have any rights ... to receive payment of principal,

interest or any other amount payable hereunder except through a Lender and as provided in this

Section 11.14(b )" (id.).

In January 2013, after LIFE defaulted on the loan, it agreed, along with ISM Agency, to

tum over to HSH the collateral that secured the loan pursuant to a Standstill Agreement

(Complaint, ,i,i 22-24; Standstill Agreement, NYSCEF Doc. No. 3). According to the Standstill

Agreement, LIFE and ISM Agency owed HSH an aggregate principal amount "not less than

$55,000,000" plus interest, costs, expenses, attorneys' fees, and other charges or contractual

obligations (Standstill Agreement, Recitals, § C). Pursuant to the Standstill Agreement, LIFE

agreed that "[s]ubject to the occurrence of a Trigger Event ... [LIFE] hereby surrenders, delivers,

grants and turns over to Collateral Agent [Wells Fargo Bank, N.A. ], and Guarantors [ISM Agency]

1 The LSA defines a "Qualified Purchasing Lender" as a "financial institution organized under the laws of a country which is a member of the Organization for Economic Co-operation and Development and that has a long-term unsecured senior debt rating of least A and A by S&P and Moody's, respectively (or the equivalent thereof)" (LSA, § 1.1). 153100/2023 LIFE INSURANCE FUND ELITE, LLC. vs. HAMBURG COMMERCIAL BANK AG ET Page 2 of 18 AL Motion No. 002

[* 2] 2 of 18 INDEX NO. 153100/2023 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 01/03/2024

hereby acknowledge and consent to such surrender, delivery, grant and turnover by [LIFE] to

Collateral Agent, peaceful possession of the Collateral" (id., §§ 2.1-2.1 [a]). Additionally, LIFE

and ISM Agency "waive[ d] all of their respective rights to notification" as to the "sale or other

disposition by Collateral Agent of the Collateral" pursuant to the UCC (id., § 2.1 [b ]).

The complaint alleges that, after HSH took control of the collateral insurance policies and

paid $500,000 in reinstatement fees, the policies were worth $70 million (Complaint, ,i 30). In

addition to the value of the insurance policies, the trust also allegedly held a $62 million receivable

from Avon Capital LLC ("Avon"), a former defaulting member of Plaintiff, bringing the total

value of the LIFE assets HSH held to $132 million (id., ,i,i 32-36). LIFE alleges, that after taking

control of the assets, HSH effected an unauthorized disposition of collateral by improperly

claiming in disclosures to have merged with LIFE and treating income from the life insurance

policies as "Other operating income" on its balance sheet (Complaint, ,i,i 57, 67). The complaint

alleges that HSH concealed this improper purported merger by keeping two separate sets of

financial records, one that treated LIFE as a subsidiary ofHSH and one that treated the relationship

as a loan, "in connection with which the bank sent LIFE phony quarterly cash and collateral

reports" (id., ,i,i 58-61 ). Subsequently, HSH allegedly pursued the trust's breach of contract claim

against Avon, obtained a judgment for the trust of over $86 million in a 2016 arbitration, but then

took no steps to collect the award (id., ,i 71). LIFE alleges, that through booking the trust's

judgment as its own asset and using that asset as leverage to settle a different lawsuit against Avon,

HSH engaged in another improper disposition of assets (id.).

In 2018, Promontoria, a company consisting of a "consortium of private equity investors"

led by Cerberus Capital Management LP ("Cerberus"),2 purportedly purchased a portfolio ofloans

2 The complaint alleges that Defendant Cerberus European is a subsidiary of Cerberus, which is not a party to this litigation (Complaint, ,r 10). 153100/2023 LIFE INSURANCE FUND ELITE, LLC. vs. HAMBURG COMMERCIAL BANK AG ET Page 3 of 18 AL Motion No. 002

[* 3] 3 of 18 INDEX NO. 153100/2023 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 01/03/2024

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Bluebook (online)
2024 NY Slip Op 30014, Counsel Stack Legal Research, https://law.counselstack.com/opinion/life-ins-fund-elite-llc-v-hamburg-commercial-bank-ag-nysupctnewyork-2024.